Miller Thomson’s Tax Litigation lawyers are dedicated to finding the ultimate solution to a client’s federal, provincial or international tax dispute problem(s). We have substantive expertise on a broad range of complex tax matters, as well as the knowledge and experience dealing with provincial, federal and international nation-state tax authorities. Since tax disputes and the associated tax litigation can be either or both civil and/or criminal in nature, we have proven and successful expertise in both the civil and criminal areas of tax law. Our tax litigators include former Department of Justice counsel in both the civil and criminal tax fields. We help clients manage the audit process, internal government appeals process, and we can represent clients at all levels of court – from the provincial courts to the Supreme Court of Canada. Our clients range from Canadian-based corporations, multinational companies with operations based in Canada, manufacturers, financial service companies, insurance companies, technology-based corporations and many more, including the average Canadian citizen.
We have the know-how to properly deal with audits, the preparation of Notices of Objection and Notices of Appeal to respond to enquiries by the tax authorities including such statutory administrative enforcement tools such as Requirements for information. We can also prepare Voluntary Disclosures and defend against charges of tax evasion and misrepresentation or other tax-related criminal charges. Whatever a client’s tax dispute resolution needs, we have the ability and capacity to spearhead a successful campaign to either resolve the tax dispute or to effectively litigate it before the courts.
Our success rate in court matters remains unsurpassed. Listed below is a representative sample of the different types of tax litigation matters that we have won on behalf of our clients:
- Income Tax Litigation ranging from business expenses to transfer pricing cases.
- Provincial Tax matters covering Retail Sales Tax challenges to Employer Health Tax Issues.
- Rectification matters.
- Recission issues.
- Appeals, covering both judicial issues, appeals and leave applications to the Supreme Court of Canada, as well as Supreme Court cases.
- Criminal Tax matters, involving investigations, Charter challenges, jury and non-jury trials.
David Chodikoff quoted in Worldwide Tax Daily article
David Chodikoff is quoted in a Worldwide Tax Daily article titled, “Multinational Enterprises Concerned About Possible Misuse of CBC Reports”.
David Chodikoff featured in article on tax evasion
The CBA National Magazine article discusses Canada’s response to large-scale overseas tax evasion. David Chodikoff leads Miller Thomson’s national Tax Ligitation group. He recently co-authored International Tax Evasion in the Global Information Age, an analysis of the new laws governing the global exchange...
Miller Thomson wins M&A Awards
Miller Thomson LLP was recently named the winner of the ACQ Global Award 2014 for Tax Litigation Law Firm of the Year- Canada and the Transfer Pricing Law Firm of the Year- Canada. A leading global M&A magazine, ACQ polled...
David Chodikoff’s Tax Litigation book now available from Thomson Reuters
Congratulations to David Chodikoff on the release of his book, Tax Litigation. This is David’s fifth published work. He is the general editor of the book and co-author of the Canadian chapter along with corporate and commercial associate Laura Etherington. Tax Litigation is...
David Chodikoff’s Tax Litigation book to be launched at the International Bar Association Conference in October
Miller Thomson congratulates David Chodikoff on the upcoming October release of his book Tax Litigation. This is David’s fifth published work. He is the general editor of the book and co-author of the Canadian chapter along with corporate and commercial associate...
David Chodikoff interviewed by CBC on offshore tax evasion
David Chodikoff was interviewed by CBC’s The National for a story on offshore tax evasion that aired on Wednesday, June 12. David’s interview was part of a CBC News report on their findings that the government overstated its offshore tax-evasion...
David W. Chodikoff selected as one of the leading tax controversy advisors in the world
David W. Chodikoff has been selected as one of the leading tax controversy advisors in the world and will be included in the International Tax Review’s Tax Controversy Leaders Guide of 2013
Miller Thomson Saskatoon is pleased to announce that Mr. Lyle Bouvier has joined the firm as a partner. Lyle brings with him 14 years of experience in tax litigation with the Department of Justice.
Lyle has argued cases in all levels of court and has extensive experience in the Tax Court of Canada, Federal Court Trial Division and Federal Court of Appeal.
Sheldon Silver named a top tax litigator in Canada by Chambers Global.
Mr. Silver, a member of Miller Thomson’s Corporate Tax and Tax Litigation and Dispute Resolution groups, was named a “Senior Statesman” in the Chambers Global 2011 report on Canada’s top tax litigators. In this March 24th article in the Globe and...
David Chodikoff speaks on Essential Tax Updates
David Chodikoff is presenting on “Essential Tax Updates: Dividend Traps, Small Business Deductions, Rectification and Privilege” at the 2017 OBA Institute.
David Chodikoff speaks on Driving a culture of legal and ethics compliance at the 15th General Counsel’s Role in Maximizing Board Effectiveness Course.
Bill Fowlis presents to the Rotary Club of Calgary on “Tax Planning with respect to the Ownership of US Real Property by Canadians”
Bill Fowlis instructs a course for the Institute of Chartered Accountants of Alberta in Calgary Entitled, “Taxation of Family Trusts – Advanced”
Bill Fowlis instructs a course for the Institute of Chartered Accountants of Alberta in Calgary Entitled, “Taxation of Family Trusts – Basic”
Shashi B. Malik speaks on “Planning for the Tax Efficient Sale of Business” at a luncheon presentation to CIBC and CIBC WoodGundy Clients June 1st, 2011.
Shashi B. Malik presents to the Entrepreneurial CA’s of Calgary on “Restructuring for the Sale of a Business” March 16th, 2011.
( Available in French only )
Vérifications fiscales… Évitez la catastrophe!
Tout entrepreneur doit savoir comment agir face à une demande de vérification fiscale de Revenu Québec ou de l’Agence du revenu du Canada. Lors de ce « Lunch & Learn » présenté à La Gare|Espace collaboratif, vous obtiendrez des conseils pratiques pour vous y...
Recent Tax Developments 2011 – Calgary
Miller Thomson’s Calgary Tax Group hosts a breakfast seminar on “Recent Tax Developments.”
How Pharmacists Can Protect Themselves From the CRA in the Coming Years
Taxes & Wealth Management, Issue 9-1
Tax Evasion: Some Recent Global Developments
It's Personal (Preserving Wealth for People and Private Companies)
Including a report from the IBA.
A Brief Summary of the Post STEP Conference Session
It’s Personal (Preserving Wealth for People and Private Companies) Special Edition, Volume 5, Issue 3
CRA audit project targets high-net-worth individuals
The Lawyers Weekly, Vol. 30, No. 45, 13
2011 Federal Budget Minister of Finance Jim Flaherty today tabled the 2011 Federal Budget (the “Budget”) entitled “A Low Tax Plan for Jobs and Growth”. We are pleased to provide our summary of tax measures contained in the Budget. There...
Business Tax Measures
IN THIS SECTION: Manufacturing and Processing Sector: Accelerated Capital Cost Allowance Clean Energy Generation Equipment: Accelerated Capital Cost Allowance Qualifying Environmental Trusts Intangible Capital Expenses in Oil Sands Projects Stop-Loss Rules on the Redemption of a Share Partnerships – Deferral...
Customs Tariff Measures
IN THIS SECTION: Customs Tariff Simplification Facilitating Low Value Imports Customs Tariff Simplification The Federal Government announced the initiation of a process to simplify the Customs Tariff in order to facilitate trade and lower the administrative burden for businesses. This...
Personal Tax Measures
IN THIS SECTION: Children’s Arts Tax Credit Volunteer Firefighters Tax Credit Family Caregiver Tax Credit Medical Expense Tax Credit for Other Dependants Child Tax Credit Eligibility Tuition Tax Credit – Examination Fees Education Tax Measures – Study Abroad RESPs –...
Other Tax Measures
IN THIS SECTION: Aboriginal Tax Policy GST/HST Changes Aboriginal Tax Policy The Federal Government expressed its continued support of initiatives that encourage the exercise of direct taxation powers by Aboriginal governments including, in particular, the entering of arrangements respecting sales...
Previously Announced Measures
The Budget confirms the Federal Government’s intention to proceed with the following previously announced tax and related measures, as modified to take into account consultations and deliberations since their release: Legislation relating to measures announced in the March 2010 Budget (including...